He appears to have made false certifications under Sarbanes Oxley. Nothing particularly complicated in that because either making knowingly a false certification of compliance or negligence in making a required certification is a criminal act.
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Sen Charles Grassley (R-Iowa) is probing longtime Hillary Rodham Clinton aide’s employment status, asking how Huma Abedin got a sweetheart deal as a private six-figure consultant while at the State Department. Abedin is married to former Rep. Anthony Weiner, who’s in the NYC mayoral race. The two hauled in as much as $350,000 in outside income on top of Abedin’s $135,000 government salary after Weiner quit Congress over a sexting scandal.
Abedin was assigned “special government employee” status, and was able to haul in cash as a private contractor. One of her clients was Teneo Holdings, a consulting firm founded by Bill Clinton aide Doug Band.
Quoting from Teneo’s Web site, which calls the firm the “next chapter in strategic advisory,”
NOTE: Last Dec, a former MF Global employee accused former president Bill Clinton of collecting $50,000 per month through his Teneo advisory firm in the months before MFG careened towards its Halloween filing for Chapter 11 bankruptcy, reports Human Events.
Bill Clinton is the chairman of Teneo's advisory board.
Teneo was hired by MF Global’s former CEO Jon S. Corzine to improve his image and to enhance his connections with Clinton’s political family, said the employee, who asked that his name be withheld because he feared retribution, according to HE. The Teneo contract with MF Global lasted at least five months, the souce said. “The board cancelled it after Corzine resigned.”
The source, who is no longer associated with MF Global, said Teneo is a dual-track company with one side devoted to merchant and investment banking and the other side set up to provide image and strategy consulting services.
The trustee for investors later sued JPMorgan bank for return of about $450M that MFG had transferred to the bank.
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They need to mobilize the Bank Secrecy Act---in which banks are required to establish, implement and maintain programs designed to detect and report suspicious activity indicative of money laundering and other financial crimes.
The Bank Secrecy Act was enacted to protect the public from harm by identifying and detecting money laundering from criminal enterprises, terrorism, tax evasion or other unlawful activities.
L/E needs to examine Corzine and Clinton's bank accounts
<><> Joint bank accounts might be used to facilitate the transfer of of govt funds. MFG monies may pay for personal and private expenses, credit cards, real estate sunsidies and vehicle purchases.
<><> To cover their tracks, fake invoices might be created to show that money deposited into accounts was being used for legitimate investment purposes.
The scheme might be advanced by issuing phony statements of payments from financial sources that actually covered the transfer of funds for MFG insiders own use.
<><> L/E is directed to get ahold of: (1) copies of MFG checks, (2) wire transfers, (3) account statements, (4) invoices, (5) bills, (6) delivery tickets, (7) correspondence including e-mail, contracts, loan agreements, and, (8) any other books or records. L/E should also explore (a) monies paid to brokers, sub-brokers, (b) family members, (c) mortgage brokers, (d) financial managers, and, (e) real estate agents, brokers, and developers.
<><> L/E should scrutinize MFG bank accounts for suspicious activites: (A) large deposits, (B) funds transferred from one account into another, (C) frequent requests for withdrawals.
SOX is very complex. Corzine probably asserted that they have processes in place to comply. Well, they do have such processes.
A CEO cannot certify that some dishonest or careless person will not ignore or bypass these controls, because he has no way of stopping that before the fact. It is his job to insure that the processes exist and the employees are aware they are supposed to follow them.